BE Group

Reference: page 17-18

BE Group's Board of Directors has six members: five elected by the General Meeting (all non-executive) plus one employee representative. Three of the General-Meeting-elected members are independent of the company and its management and of major shareholders. The CEO is not a Board member.

Board diversity at year-end 2025: Women 2 (33%), Men 4 (67%); independent directors are 60% of those elected by the General Meeting; ages span 35-64.

"The Board of Directors holds the ultimate responsibility for BE Group's sustainability work, including the oversight of material impacts, risks and opportunities related to sustainability. The Board approves the company's sustainability strategy, key policies and the sustainability statement in the Annual Report." Sustainability matters are addressed by the Board at least twice a year and as needed.

Operational responsibility is split by function: Operations (E1-E5 own-operations impacts, S1 health and safety), HR (S1 personnel matters), Sourcing (upstream E1-E5, S2, S3), Finance (G1, sustainability-related financial reporting). The Sustainability Coordinator reports to the CEO and coordinates ESRS reporting. Board competence on sustainability is supported by the Coordinator's analyses, external advisory support and auditor feedback rather than a named in-house expert.

Reference: page 18

"Sustainability matters are addressed by the Board of Directors at least twice per year and additionally whenever issues arise concerning material impacts. As part of the annual strategy process, the Board considers sustainability-related risks and opportunities and how they relate to the business strategy."

The Board receives information on risk management, internal control and sustainability reporting from the Sustainability Coordinator and from the auditors through the Audit Committee. As part of the annual strategy update, the Board takes into account the impacts, risks and opportunities associated with the company's material sustainability matters. No further detail is given on the frequency or content of information packages beyond this twice-yearly cadence.

Reference: page 18

Under BE Group's remuneration policy for senior executives, variable cash remuneration "shall primarily relate to the Group's operating margin or operating result, and the underlying operating margin or operating result of the respective business area," with individual targets also possible.

"Currently, the variable cash remuneration for senior executives is not linked to any sustainability-related objectives beyond the financial targets." The company points to its remuneration report on www.begroup.com for further detail. There is, in other words, no sustainability-linked incentive component for 2025.

Reference: page 19

"BE Group does not have a unified, formalized due diligence process. The activities that constitute the company's due diligence are integrated into existing policies, risk processes, and operational procedures rather than consolidated into a dedicated framework."

The company maps its practice against the six due-diligence steps: (1) embedding in governance/strategy via the Code of Conduct, Supplier Code, Environmental Policy, Safety First Policy and Anti-Corruption Policy; (2) stakeholder engagement through the 2023-2024 materiality interviews, though "the company has no established procedures for engaging with affected communities or workers in the value chain beyond the first tier of suppliers"; (3) identifying impacts through the DMA and risk assessment; (4) action via topical policies; (5) tracking via health, safety, energy and emissions KPIs, though "the company has not conducted a systematic evaluation of policy effectiveness during the reporting period"; (6) remediation via the Trumpet whistleblowing service, noting "BE Group has no dedicated channels for workers in the value chain or affected communities to raise complaints directly with the company."

The statement includes a page-reference table mapping each step to the relevant disclosure requirement.

Reference: page 20

"BE Group has not established a formalised framework for internal control over sustainability reporting for the 2025 financial year. Sustainability information has been collected from operational functions and quality-assured by the Sustainability Coordinator. No systematic risk assessment of the reporting process has been carried out."

The company states it "intends to evaluate the need for formalised control structures for sustainability reporting during the upcoming period," indicating this is a first-year gap the company itself acknowledges rather than a mature control environment.

Reference: page 19-20

BE Group is "a leading trading and service company within steel, stainless steel and aluminium," aiming "to be the most profitable and growing steel distributor in the markets in which it operates." Net sales in 2025 were SEK 3,934 M. Total employees at year-end: 513 (Parent company 9, Sweden 247, Finland 257); average during the year was 555.

"As an independent actor in the market, BE Group aims to use its influence to contribute to a low-carbon society by offering a comprehensive range of products with a low CO2 footprint." The company uses World Steel Association data for internal "green steel" classification, since "there is no uniform definition of 'green/sustainable/low-CO2 steel.'" A stated strategic priority going forward is to "expand expertise in 'sustainable steel'" and increase traceability and transparency across the value chain.

The value chain runs from upstream raw-material extraction and steel/aluminium production, through BE Group's own warehousing, cutting, blasting and painting services in Sweden and Finland, to business-to-business customers in construction and manufacturing; the company has no direct-to-consumer sales.

Reference: page 20-21

"BE Group strives to maintain an open dialogue with its identified key stakeholders to ensure that their needs and expectations are met." Identified groups: customers, employees, shareholders, suppliers, and society.

Dialogue channels by group: customers (personal interaction, trade fairs, surveys, website), employees (workplace meetings, surveys, union collaboration, incident follow-up, performance reviews), shareholders (AGM, annual and interim reports, investor meetings), suppliers (quarterly meetings, cooperation projects), society (study visits, collaborative projects, sponsorship).

During the 2023-2024 double materiality assessment, interviews were held with "shareholders, trade union organisations, banks, insurance companies, customers and suppliers" to validate that BE Group's own view of its impacts did not diverge materially from stakeholder perceptions. No workers-in-the-value-chain or affected-community representatives are named among those interviewed.

Reference: page 21

"BE Group's materiality assessment has identified a number of impacts, risks, and opportunities connected to the company's operations as a steel distributor. These are concentrated in different parts of the value chain depending on the sustainability topic."

"Material negative impacts are primarily located in the upstream value chain" (GHG emissions, biodiversity, water, working conditions and community impacts tied to raw-material extraction), where BE Group "is considered to contribute... through its purchasing decisions, although with limited influence and visibility beyond the first tier of suppliers." Within own operations, the material impact is workforce health and safety, plus positive impacts as a local employer and taxpayer.

"Link to strategy and business model: The identified impacts, risks, and opportunities have a direct link to BE Group's strategy." The procurement focus addresses value-chain risk via low-carbon products and supplier traceability; the safety focus addresses own-workforce risk. As a distributor rather than a producer, "the most material environmental and social impacts lie outside the company's direct control," managed indirectly through the Supplier Code of Conduct and European-focused sourcing.

During 2025 the assessment was revisited: impacts tied to the divested Polish and Baltic operations were reduced, and a war-disruption risk was downgraded and moved to the general risk section (page 13).

Reference: page 21-22

"At the end of 2023 and the beginning of 2024, BE Group conducted a materiality assessment together with an external consultancy, in accordance with the requirements of the European Sustainability Reporting Standards (ESRS)." Four phases: preparation and scoping, mapping of impacts/risks/opportunities, materiality assessment, and validation.

The mapping phase "began with a workshop in which all ESRS topical standards were systematically reviewed at sub-topic level," followed by department-level follow-ups and stakeholder interviews (shareholders, trade unions, a bank, an insurer, customers, suppliers) to check BE Group's conclusions against outside perceptions. The materiality workshop had "broad representation from the management teams of the business units," with results validated by Group Management and presented to the Board.

"During 2025, the materiality assessment was reviewed, and revisions were made in necessary areas," chiefly reflecting the divestment of the Polish and Baltic operations and a downgraded war-disruption risk (moved to the general risk section, page 13).

Reference: page 22-23

BE Group publishes a full ESRS content index (IRO-2) listing, standard by standard, which disclosure requirements it covers and at what page, including the datapoints it discloses under other EU legislation (SFDR, Pillar 3, the Benchmark Regulation, the EU Climate Law) embedded in GOV-1 and E1.

The index confirms E3, E4 and G1 are addressed largely through the generic cross-cutting MDR-P/MDR-A/MDR-T/MDR-M labels rather than topic-numbered codes, that E1-7, E1-8 and G1-5 are marked "Not material," and that S4 (Consumers and end-users) is marked "Not material" in full. This index is the basis for every "reported" determination in this file: a disclosure requirement is treated as reported only where BE Group's own index lists it with a page reference.

Reference: page 25

"BE Group has not established a comprehensive transition plan to achieve climate neutrality."

Own operations: "A number of measures with the potential to reduce emissions from the company's own operations have been identified, including a transition from fossil propane to biogas at production sites. These measures have not yet been formalised into a time-bound plan with corresponding investment decisions."

Value chain: the majority of climate impact sits upstream (Scope 3); BE Group's influence is "limited to supplier selection and purchasing decisions," and the company monitors how ETS/CBAM will shift the green-steel market.

"Work to develop a formalised plan to achieve net-zero emissions is scheduled to begin in 2026." No 1.5°C scenario alignment, SBTi validation or locked-in emissions assessment is mentioned anywhere in the statement.

Reference: page 25-26

BE Group has no standalone climate policy; it relies on the Environmental Policy (own operations) and the Code of Conduct for suppliers (value chain).

The Environmental Policy commits to "complying with applicable environmental legislation, using energy and natural resources efficiently by reducing, reusing and recycling... and working to reduce emissions from operations," with a goal of ISO 14001 certification across all units - achieved in 2025 for all sites. The company has "adopted a long-term commitment to climate neutrality, with targets to achieve net-zero emissions for Scope 1 and Scope 2 at the latest by 2040 and for Scope 3 at the latest by 2045."

The Supplier Code of Conduct "sets requirements related to environmental considerations and energy efficiency," expecting suppliers to reduce emissions, conserve energy and set energy-efficiency targets, with energy efficiency becoming "increasingly... a selection criterion alongside quality, price and delivery time." Both policies were developed internally; the company states that, absent documentation, "no stakeholder dialogue was conducted during the original development."

The President and CEO owns both policies.

Reference: page 26

BE Group reports concrete but unquantified or partly quantified actions for 2025: Energy efficiency in buildings - demand-controlled ventilation upgrade at the Lahti facility; LED conversion at the Turku office ("estimated annual savings potential of 40,000-70,000 kWh"); LED investment in Swedish operations; new electricity meters at the main Swedish site for real-time monitoring.

Logistics and transport - route optimisation in Sweden to improve fill rates; cutting operations centralised to Norrköping after phasing out external capacity, "which has shortened logistics flows," though "the company is unable to quantify the total emission impact of these measures."

Vehicle fleet - continued electrification of the company car fleet; "91 percent of newly leased vehicles were electric" in the period. Diesel forklifts are being gradually replaced by electric models in Finland; compressed-air leakages were fixed in Sweden, again unquantified.

"BE Group has not identified any activities that require significant Capex or Opex" for these measures - notwithstanding that the EU Taxonomy section of the same report records SEK 11.3 M of 2025 CapEx (21% of total CapEx) tied to the leased electric vehicles and SEK 465 thousand to the LED lighting installations (pages 78-79), a disclosure the climate section does not cross-reference.

Reference: page 26

BE Group discloses two long-term net-zero targets: Scope 1 and 2 net-zero emissions by 2040 (base year 2025); Scope 3 net-zero emissions by 2045 (base year 2025).

"Interim targets and a detailed reduction trajectory to reach these goals have not yet been established. Work to develop a formalised transition plan, including interim targets, is planned to begin in 2026." No near-term (e.g. 2030) target, no SBTi validation, and no statement of 1.5°C alignment accompanies either target; 2025 is used as the base year because, per the statement's introduction, "BE Group has not performed quantitative comparisons with prior-year data."

Reference: page 27

Reporting covers operations in Sweden and Finland under operational control, classified under NACE codes G46.72, C25.62 and H52.10 - "all of which are classified as sectors with high climate impact in accordance with ESRS E1-5.38."

2025 figures (MWh): fossil fuel consumption (crude oil/petroleum products 3,550; natural gas 964; coal 0) plus 1,334 from fossil-sourced purchased electricity/heat = total fossil energy consumption 5,848 (28% of the mix). Nuclear-sourced consumption: 9,164 MWh (43.9%). Renewable: 354 MWh fuel (HVO biodiesel) plus 5,463 MWh purchased/acquired renewable electricity/heat = total renewable energy consumption 5,817 (27.9%). Total energy consumption: 20,829 MWh; energy intensity 5.29 MWh/SEK M of net sales.

Energy carriers: propane (plasma cutting, pre-heating, painting), diesel (forklifts, transport), natural gas (one Finnish facility) on the fossil side; HVO biodiesel (forklifts) renewable; purchased electricity is nuclear in Sweden and a nuclear/hydropower mix in Finland; district heating varies by local supplier mix.

Reference: page 27-28

Emissions follow the GHG Protocol. "In accordance with the transitional provisions in ESRS 1 Appendix C (Regulation (EU) 2023/2772), the company, having fewer than 750 employees, has elected to omit Scope 3 emissions and total greenhouse gas emissions for the first reporting year." Biogenic emissions are not reported "due to lack of available data."

2025 figures: Gross Scope 1: 1,066 tCO2e (0% covered by regulated emissions trading). Scope 2, location-based: 3,198 tCO2e; market-based: 462 tCO2e. Gross Scope 1+2 (market-based): 1,528 tCO2eq. GHG intensity: 1.08 tCO2eq/SEK M (location-based) and 0.38 tCO2eq/SEK M (market-based) of net sales.

Scope 1 factors draw on DEFRA 2025 and Swedish Energy Agency fuel statistics (GWP per IPCC AR5); Scope 2 uses AIB Residual Mix (location-based) and Guarantee-of-Origin factors (market-based). Finnish district-heating factors come from suppliers' own calculations, and some consumption volumes are estimated rather than metered - flagged by the company as a source of uncertainty. No Scope 3 or total figure is disclosed this year.

Reference: page 21, 24-25

Back-filled from ESRS 2 IRO-1 and the E1 climate section, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

BE Group's material-IRO table for E1 classifies its climate risks as both physical ("potential logistical disruptions caused by extreme weather events," affecting inbound and outbound distribution, upstream and own operations) and transition-related (higher prices from carbon pricing under ETS/CBAM, and a "Possibility" opportunity from green-steel competitiveness) - satisfying the basic classification the disclosure asks for.

Beyond that classification, no methodology for assessing exposure and sensitivity is described, and no scenario analysis was performed: "BE Group has considered the nature, scale and geographical location of its operations when assessing its impacts on climate change. The company has not carried out in-depth analyses in accordance with ESRS E1, IRO-1, ESRS 2 or SBM-3." No named scenario (e.g. an SSP/RCP or IEA pathway), temperature projection, or scope-of-operations statement for a scenario exercise appears anywhere in the statement.

Reference: page 24-25

Back-filled from ESRS 2 SBM-3 and the E1 climate section, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

BE Group states plainly that it has not performed a resilience analysis as defined under the ESRS: "No resilience analysis has been carried out in relation to the identified material physical risks." This sits alongside the broader admission that "the company has not carried out in-depth analyses in accordance with ESRS E1, IRO-1, ESRS 2 or SBM-3."

No statement addresses capacity to adjust or redeploy assets, areas of uncertainty in a resilience assessment, or how the (not-yet-formalised) transition plan would contribute to resilience - consistent with there being no analysis to report on.

Reference: page 29

BE Group has no standalone pollution policy; it relies on the Environmental Policy (own operations) and the Supplier Code of Conduct (value chain) - "For more information on these policies, see E1-2."

Own operations: the Environmental Policy covers "complying with applicable environmental legislation, working to reduce emissions from operations, and maintaining preparedness to manage environmental incidents and accidental releases." "Responsible chemical handling is part of daily operations," monitored under ISO 14001, which covered all sites in 2025.

Value chain: the Supplier Code "sets requirements regarding environmental considerations related to air emissions, wastewater and stormwater management, waste management, and the handling of substances of concern," requiring suppliers to hold environmental permits and assess soil-contamination risk from current or historical activity.

Reference: page 29

Own operations: "All BE Group production facilities have action plans to meet statutory requirements and certification requirements aimed at minimising emissions and associated environmental impacts," covering chemical handling, emissions risk reduction and incident reporting.

A concrete 2025 action: BE Group "concluded environmental soil investigations at a former unit in Malmö" (operated 1974-2021), ongoing since 2021, which mapped historical petroleum-hydrocarbon and PAH/metals contamination and led to a remediation notification to the supervisory authority; remediation is planned for 2026 at an "estimated cost of... approximately SEK 2 M," targeting the Swedish EPA's guidelines for less-sensitive land use.

Value chain: impacts are addressed "indirectly through the requirements in the Supplier Code of Conduct"; "the company has not undertaken specific actions targeting pollution generated by suppliers during the reporting period," and value-chain pollution data "is not available."

Reference: page 29

"BE Group has not established specific pollution-related targets but continuously evaluates operations against applicable threshold values based on environmental legislation and permit conditions." No quantified pollution-reduction target (air, water, soil or substances of concern) is set for either own operations or the value chain.

Reference: page 29 (BP-2, page 16)

"BE Group has no data to report in this area, as the data quality has been assessed as insufficient, with the exception of VOC emissions reported under E2-5, see BP-2."

The basis-of-preparation section explains why: "the available data sources consist of periodic control measurements carried out in accordance with the requirements of supervisory authorities. These measurements are not considered to provide a reliable basis for estimating annual total quantities, and... additional efforts to bridge this uncertainty have not been deemed an appropriate use of the company's resources." This is a stated data-quality limitation, not a materiality finding - BE Group's IRO table identifies air/water/soil pollution from own operations and the upstream value chain as a material potential negative impact.

Reference: page 30

Substances of concern (generated/used): "VOC emissions (Volatile Organic Compounds) from painting lines for long products amounted to 781 kg during the reporting period," based on paint-supplier specifications and third-party afterburner test reports.

Substances of very high concern, leaving the undertaking (sold in products): BE Group sells products containing lead (on the REACH Candidate List) - specific engineering-steel grades (EN 11SMnPb30+C, 36SMnPb14+C, EN14APb), aluminium alloys (EN 2007, 2011, 2030, 6012, 6026, 6262), and lead sheet as a customer-specific product. "BE Group estimates that 21.5 tonnes of products containing lead left the company during the reporting period, of which 21 tonnes were lead sheet and the remainder trace amounts in other products," estimated from REACH-declared maximum lead content (0.1% of weight) and sales data. "REACH compliance is maintained, and safety data sheets are provided to customers." "More detailed data cannot be reported due to limitations in data collection."

This addresses both the generated/used limb (VOC) and the outflow limb (lead-containing products sold), with SVHC presented separately from the general substances-of-concern figure, as paragraph 35 requires.

Reference: page 31

"BE Group does not have a standalone policy for water and marine resources; instead, water management is covered by the company's environmental policy. For more information, see E1-2."

"The company is committed to minimising environmental impacts from water use in its production activities. Continuous monitoring, reporting and evaluation of water use form part of its compliance with local regulatory requirements and its ISO 14001 certification." No separate value-chain water policy is described beyond the general Supplier Code of Conduct environmental clauses covered under E1-2/E2-1.

Reference: page 31

"BE Group adheres to statutory requirements and environmental certification requirements regarding water use, with the aim of reducing total water demand and consumption. No specific actions have been carried out or resources allocated during the reporting year." Freshwater used in closed cooling-bath systems for gas cutting is reused rather than discharged, per the topic introduction, but no dedicated water-reduction project is reported for 2025.

Reference: page 31

"BE Group does not consider water use within its own operations to be material and has therefore not set any specific targets. However, water consumption in production is monitored in accordance with local environmental regulations and certification requirements." No numeric water target exists for either own operations or the value chain.

Reference: page 32

Filed under the generic "MDR-P" row in BE Group's own index. "BE Group does not have a specific policy for biodiversity and ecosystems."

Own operations: "the company's environmental policy includes general commitments that indirectly relate to ecosystem protection, such as at the minimum complying with environmental legislation, conserving natural resources, reducing emissions and maintaining preparedness to manage environmental incidents... The policy does not address biodiversity explicitly."

Value chain: "BE Group's Supplier Code of Conduct includes environmental requirements that may indirectly protect ecosystems, such as compliance with environmental legislation concerning soil contamination, wastewater and stormwater management, air emissions and waste management... The Supplier Code of Conduct does not explicitly address biodiversity."

Reference: page 33

Filed under the generic "MDR-A" row in BE Group's own index. "BE Group has no specific actions directed at biodiversity and ecosystems." Material biodiversity impact is identified as upstream, at the raw-material extraction stage (mining of iron ore, bauxite and alloying metals); as a distributor, BE Group addresses this only indirectly through the Supplier Code of Conduct, with no dedicated biodiversity action taken during 2025.

Reference: page 33

Filed under the generic "MDR-T" row in BE Group's own index. "BE Group has not established specific targets related to biodiversity and ecosystems. The company also has no specific actions directed at biodiversity and ecosystems." No effectiveness-tracking mechanism in lieu of a target is described either.

Reference: page 33

Filed under the generic "MDR-M" row in BE Group's own index. "BE Group has not established specific metrics related to biodiversity and ecosystems. The development of measurable targets and indicators for future reporting periods is under evaluation." No land-use, habitat or species-impact metric is disclosed for own operations or the value chain; the company explicitly applies ESRS 1 Appendix C transitional provisions for E4 "primarily regarding quantitative metrics" (SBM-3, page 32).

Reference: page 34

"BE Group does not have a standalone policy for resource use and circular economy. Resource and waste management are covered by the company's environmental policy and its Supplier Code of Conduct. For more information, see E1-2."

Own operations: the Environmental Policy covers "efficient use of energy and natural resources through reduction, reuse and recycling, as well as efforts to reduce waste from operations," backed by ISO 14001 certification across all units in 2025. Value chain: the Supplier Code requires suppliers to "handle and dispose of hazardous and non-hazardous waste in accordance with applicable legislation and to strive to reduce waste and emissions through reduction, reuse and recycling."

Reference: page 34

"No activities or resources with a verifiable positive impact on resource use and the circular economy were carried out or allocated during the reporting period." This is a direct nil disclosure - BE Group reports that, unlike its climate and pollution actions, no dedicated resource-efficiency project was run in 2025 beyond routine operations.

Reference: page 34

"BE Group has not established specific targets related to resource use and circular economy beyond general commitments to resource efficiency as outlined in the environmental policy. The company is postponing the establishment of specific targets until its new business system has been implemented across all units, to ensure comparability of datasets, which currently vary between sites." The stated reason is a live data-systems transition, not a materiality finding.

Reference: page 34-35

"BE Group is a distributor of steel and metal products and does not manufacture its own materials. Resource inflows consist primarily of purchased steel and metal products, as well as packaging materials used for customer deliveries." Purchased material arriving at BE Group's sites in 2025 totalled 245,211 tonnes (steel 243,068 t; aluminium 2,112 t; other 31 t).

Packaging inflows by material (Sweden/Finland/Group tonnes): wood 1,650/1,889/3,539; paper/cardboard 13/71/84; plastic 38/34/72 (of which 15 t of Finnish PET strapping is "100% recycled raw material"); steel 9/47/56; textile slings 13/0/13; total packaging 1,723/2,041/3,764. Finnish EUR pallets are reused at "exceeding 90 percent" under a recirculation commitment.

"Detailed quantitative information on scrap content in inputs is not available during the first reporting period in accordance with the transition provisions for value chain data," so the recycled-content share of purchased steel/aluminium itself is not quantified.

Reference: page 35

Products delivered to customers in 2025 totalled 241,360 tonnes (inventory sales incl. direct sales 137,901 t; production-service sales 103,459 t; other 889 t - steel and aluminium not separately split in the extracted figures, but matching the inflow split by material).

"Steel is a material with a high inherent recyclability. End-of-life products are managed by the customer but are expected to be returned largely to the material cycle through scrap recycling. The company does not have any take-back programmes or return flows for sold products. Detailed information on the actual recycling rate in the customer phase is not available."

Reference: page 35-36

Waste arises mainly from processing and distribution, not at the customer stage: "the largest fractions consist[] of wooden packaging materials, process-related waste such as cutting fluids and oils, as well as packaging materials," plus metal scrap (the largest fraction by weight, returned to the steel industry for remelting).

2025 figures (tonnes, ESRS E5-5 paragraph 37 references as printed): Hazardous waste 25 (excl. disposal 4, of which recycling 4; disposed 21 - incineration 15, landfill 0, other disposal 6). Non-hazardous waste 23,243 (excl. disposal 22,696, of which recycling 22,694; disposed 547 - incineration 136, landfill 2, other 0). Total waste 23,268, of which 98% excludes disposal (i.e. is recovered) and 2% is disposed. Separately, metal scrap sent to energy/material recovery: steel 22,498 t, aluminium 22 t, total 22,520 t.

"For hazardous waste, the majority (84%) is treated through disposal, primarily via incineration of emulsions, cutting fluids, and plasma dust/zinc dust... For non-hazardous waste, most (98%) is sent for recovery, mainly through material recycling of metal scrap, wood and cardboard, as well as energy recovery." Waste is classified under the European Waste Catalogue; recovery/disposal split follows EU R/D codes.

Reference: page 41

Filed under the generic "MDR-P" row. BE Group's Code of Conduct sets out employee rights including "the right to be represented by a trade union in negotiations," "fair employment and wage conditions," "a workplace free from discrimination and harassment," and "zero tolerance for child labour." A Privacy Policy (CFO-owned, adopted 2022) covers personal-data handling for employees and contracted personnel.

The Safety First Policy (adopted 2019) is "founded on the principle that all accidents can be prevented and that safety must always come first," covering risk assessment, follow-up, training and behaviour-based safety; one Swedish site (Barlastgatan) holds ISO 45001 certification. The Whistleblowing Policy (adopted July 2022) routes reports through the external "Trumpet" service with anonymity and anti-retaliation protection for reporters and those who assist them. All four policies were developed internally, with the company noting that, absent documentation, it "assumes that no stakeholder dialogue was conducted" at inception.

Reference: page 41

Filed under the generic "MDR-P" row via the Whistleblowing Policy: reports are handled through the external "Trumpet" service, administered by an independent third party, "under strict confidentiality by a limited group consisting of the external service administrator and BE Group's internal Whistleblowing Committee." "Reports may be submitted anonymously," and "individuals who report in good faith are protected against retaliation, a protection that also extends to colleagues and union representatives who assist in the reporting process." The policy covers "all individuals engaged in work-related contexts within BE Group," including Board members, employees, interns and contracted personnel.

Reference: page 42

Filed under the generic "MDR-A" row. BE Group's identified impact is health and safety; actions taken include "gradually replacing diesel forklifts with electric forklifts, conducting air measurements at selected production facilities, performing work environment assessments and carrying out regular health examinations for employees at the production sites." "The company works actively with occupational health and safety and uses different system supports in Sweden and Finland for data compilation. In 2025, the company initiated the implementation of a joint system to enable more harmonised reporting." "The company has not identified any risks or incidents related to forced labour or child labour within its own operations."

Reference: page 42

Filed under the generic "MDR-T" row. "The company has established overarching targets related to its own workforce and monitors, among other things: the number of accidents and incidents in operations; sick leave; conducts pay equity assessments; measures employee turnover; ensures that all employees are offered regular performance development reviews." "These activities are followed up annually by the local management teams." No numeric target level is attached to any of these five areas.

Reference: page 20, 42

Headcount at year-end 2025: 513 employees total (Parent company 9, Sweden 247, Finland 257). The average number of employees during the year amounted to 555. No further breakdown by contract type (permanent/temporary), gender, or country beyond Sweden/Finland/Parent is disclosed, and no non-employee-worker (S1-7) headcount is given.

Reference: page 42

Filed under the generic "MDR-M" row. "The average number of employees in BE Group during the year amounted to 555, of which 10% were women." "As of 31 December 2025, the share of women among administrative staff was approximately 26%, while the share in production was around 3%." "Gender distribution remains a sector-related challenge, and efforts continue to assess how the company can create conditions to attract more female employees and managers." No age-distribution metric for the workforce is disclosed (age distribution is given for the Board under GOV-1, not the workforce).

Reference: page 42

Filed under the generic "MDR-M" row. "During the year, 9 accidents resulting in more than one day of absence were reported, of which 6 occurred in Sweden and 3 in Finland." No work-related fatality count, recordable-accident rate (e.g. per hours worked), lost-day total, or work-related ill-health figure accompanies the accident count - the disclosure is limited to the raw number of accidents by country.

Reference: page 43-44

Filed under the generic "MDR-P" row. BE Group's Code of Conduct for Suppliers (revised 2023) sets minimum requirements in three areas: Working conditions (max. 60-hour working week incl. overtime, minimum wages per applicable law, statutory benefits, accident insurance, transparent time/wage records); Equal treatment (anti-discrimination on race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin or marital status; harassment-free workplace); Other work-related rights (prohibition of forced labour, trafficking and child labour; freedom of association and collective bargaining; occupational health and safety including chemical handling and emergency preparedness).

"BE Group, or a third party appointed by BE Group, reserves the right to conduct audits or on-site visits to assess supplier compliance." Suppliers not signing the Code may still be accepted "provided the supplier can demonstrate its own Code of Conduct with equivalent or higher standards" - a pragmatic concession the company attributes to several major suppliers being "international steel producers with well-established sustainability programs."

Reference: page 44

Filed under the generic "MDR-T" row. "BE Group has no dedicated channels or procedures for workers in the value chain to raise complaints or report concerns directly to the company. General contact channels are available via the company's website." Instead, "suppliers are expected to provide their own grievance mechanisms for workers and ensure whistleblower protection in accordance with applicable legislation," so "remediation of any adverse impacts on workers in the value chain is therefore primarily expected to be managed by the respective employer within the supplier chain." "BE Group did not receive any complaints from workers in the value chain during the reporting period."

Reference: page 44

Filed under the generic "MDR-A" row. "BE Group has no specific actions or strategies directed toward the identified impacts on workers in the value chain beyond the requirements established through the company's Supplier Code of Conduct." The company relies on its European-focused sourcing strategy as "an indirect risk-reducing factor," since "visibility into working conditions beyond the first tier... is limited." "No specific actions to address these risks were implemented during the reporting period."

Reference: page 44

Filed under the generic "MDR-M" row. "BE Group has not established specific targets relating to workers in the value chain. The development of measurable targets and indicators is being evaluated for future reporting periods." No effectiveness-tracking metric in lieu of a target (e.g. audit coverage rate, complaints received) is reported either, beyond the "zero complaints received" fact already noted under S2-3.

Reference: page 45-46

Filed under the generic "MDR-P" row. BE Group's Code of Conduct (last updated 2018) states the company "aims to act as a socially responsible company" and contributes to local economies "by conducting its business professionally and profitably, thereby creating jobs and supporting customers." "The company has no specific community engagement policy beyond what is stated in the overarching Code of Conduct."

Via the Supplier Code of Conduct (revised 2023), suppliers "are encouraged to engage with their local communities to support social and economic development," and must exercise due diligence on mineral provenance, "including conflict minerals and minerals from Central Africa." BE Group states it "has no direct insight into or influence over the relationship between upstream actors (mines, steelworks) and their affected communities," addressing this only indirectly through the Code.

Reference: page 46

Filed under the generic "MDR-A" row. "BE Group has no specific actions targeted at the identified impacts on affected communities. The company's own operations are located in established industrial and warehouse areas with limited direct impact on surrounding communities. Any potential impacts are managed within the scope of normal operations and regulatory compliance." For the value chain, "impacts on affected communities are addressed indirectly through the requirements set out in the Supplier Code of Conduct. No specific actions were implemented during the reporting period."

Reference: page 46

Filed under the generic "MDR-T" row. "BE Group has not established specific targets relating to affected communities. The development of measurable targets is being evaluated for future reporting periods." No effectiveness-tracking mechanism in lieu of a target is described.

Reference: page 48-49

BE Group lists eight policies supporting its business-conduct work: "the Code of Conduct, corporate values, Environmental Policy, Safety First Policy, Anti-Corruption Policy, Supplier Code of Conduct, Sanctions Policy, and Whistleblowing Policy," each with a named owner (mostly the President and CEO, or the CFO) and board-level adoption dates (Code of Conduct 2018, Anti-Corruption Policy October 2021, Sanctions Policy 2023, Whistleblowing Policy July 2022).

"The Anti-Corruption Policy... prohibits employees from offering, giving, soliciting, or accepting bribes, whether directly or indirectly," regulates gifts and hospitality, and states the company "maintains political neutrality and does not make political donations." The Trade Sanction Policy screens all business partners and designates "red" (prohibited) and "yellow" (CEO-approval-required) countries, developed "in collaboration with an external law firm." All policies are delivered at onboarding and via the intranet.

Reference: page 49

"The company's Supplier Code of Conduct outlines minimum requirements and expectations in areas such as human rights, health and safety, non-discrimination, working conditions, child labour, anti-corruption, information regarding sanctions, import and export restrictions, and environmental responsibility. The Code of Conduct is signed by suppliers and monitored by the procurement organisation. As part of future development, the company plans to introduce clearer processes for supplier screening and follow-up."

Specific supplier obligations include eliminating physical risks, respecting human rights, prohibiting forced and child labour (minimum age 15 or local legal minimum), complying with REACH/RoHS, and managing waste, stormwater and air emissions responsibly. Suppliers must also avoid sanctioned counterparties and be transparent about their own customers.

Reference: page 50

"BE Group is exposed to risks of involvement in unethical business practices in areas such as sales and procurement processes. The company maintains zero tolerance for unethical business conduct." Controls include the Anti-Corruption Policy and Code of Conduct (given to all employees at onboarding), central and local authorisation manuals, payment-approval procedures and vetted procurement processes.

"Risk assessments are conducted annually at group level, and the corruption risk is assessed as low, considering factors such as geographic markets and authorisation procedures." Concerns can be raised to the immediate manager, HR, or anonymously through the whistleblowing system; the Whistleblowing Committee, which includes the Chair of the Audit Committee, handles reports "in consultation with an external party."

Reference: page 50

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

BE Group discloses no measurable, outcome-oriented anti-corruption target. Consistent with MDR-T's other limb, effectiveness is instead tracked in the absence of one: "Risk assessments are conducted annually at group level, and the corruption risk is assessed as low, considering factors such as geographic markets and authorisation procedures" (G1-3, page 50). No incidents, convictions or legal cases were recorded in 2025 (G1-4, page 50), which the company offers as the outcome of that monitoring rather than of a stated target.

Reference: page 50

"BE Group has not identified any relevant events during 2025 in relation to: convictions for violations of anti-corruption or bribery laws, or fines associated with such violations; confirmed incidents of corruption or bribery; contracts with business partners that were terminated or not renewed due to breaches relating to corruption or bribery; legal cases concerning corruption or bribery involving the company or its employees." "As no confirmed incidents, convictions, or legal cases occurred, no corrective measures related to breaches of standards have been required." A complete nil return across all four categories.

Reference: page 50

"In line with group guidelines, BE Group strives to ensure that payments are approved in a timely manner so that they are executed within the agreed payment terms with suppliers. Payments are processed at least twice per week." "Payment terms vary between 10 and 90 days and are negotiated individually with each supplier. The company strives for a minimum payment term of 30 days." "As of 31 December 2025, the average number of days it took BE Group to pay invoices was 46 days. At the end of the year, BE Group had no outstanding legal proceedings related to late payments."